```
                                                                 
Information Management: Selected Agencies' Handling of Personal  
Information (30-SEP-02, GAO-02-1058).				 
                                                                 
To obtain government services, members of the public must often  
provide agencies with personal information, which includes both  
identifying information (such as name or Social Security number, 
which can be used to locate to identify someone) and		 
nonidentifying information (such as age or gender). GAO was asked
to review agencies' handling of the personal information they	 
collect and whether this handling conforms with federal law,	 
regulation, and agency guidance.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-1058					        
    ACCNO:   A05186						        
  TITLE:     Information Management: Selected Agencies' Handling of   
Personal Information						 
     DATE:   09/30/2002 
  SUBJECT:   Data collection					 
	     Information resources management			 
	     Right of privacy					 
	     Records management 				 

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GAO-02-1058

                                       A

Report to the Chairman, Committee on Governmental Affairs, U. S. Senate

September 2002 INFORMATION MANAGEMENT Selected Agencies* Handling of
Personal Information

GAO- 02- 1058

Lett er

September 30, 2002 The Honorable Joseph I. Lieberman Chairman, Committee
on Governmental Affairs United States Senate

Dear Mr. Chairman: The security and protection of personal information 1
is a topic of growing national concern. Personal information is provided
to the government by the public for a specific purpose* to receive a
government benefit, obtain a service or loan, or participate in a program.
However, this information in

the hands of unauthorized persons can present a risk to those who provide
it* such as misuse of personal information or loss of personal privacy.

This report addresses the flow and management of personal information at
four agencies: the Departments of Agriculture, Education, Labor, and
State. At your request, we selected one information collection 2 form
requesting personal information at each of these agencies, to review its
life cycle from collection, use, dissemination, and storage, through
archiving and/ or

disposal. As agreed with your office, our objectives were to (1) document
the flow of and practices associated with the handling of personal
information within these agencies and (2) evaluate these information flows
and practices against agency and federal guidance.

To fulfill our objectives, we modeled the data flows for each of these
forms. We conducted structured interviews with top agency officials and
program managers to understand the data flow and agency practices. We also
reviewed applicable laws and regulations and analyzed agency documentation
on policies and procedures for using, protecting, making

available, and disposing of this information. We conducted our review from
March 2001 to July 2002, in accordance with generally accepted government
auditing standards. 1 Personal information is defined as all information
associated with an individual and includes both identifying information
(e. g., name, Social Security number, E- mail address, and agency-
assigned case number) and nonidentifying information (e. g., age,
finances, and gender). 2 Collections of information include (1) requests
for information for transmission to the government, such as application
forms and written report forms; (2) record keeping

requirements; and (3) third party or public disclosure requirements.

On August 19, 2002, we provided a detailed briefing 3 to your office on
the results of our work. The briefing slides are included as appendix I,
and a detailed discussion of objectives, scope, and methodology is
included as appendix II. The purpose of this report is to provide the
published briefing

slides and appendixes to you and to officially transmit our
recommendations to the Secretaries of Labor and Agriculture. In brief, we
reported that these four agencies* handling of personal information varied
greatly* including the types and amount collected* and a wide range of
personnel had access to the information. Further, these agencies generally
followed the applicable laws and regulations in the collections we
reviewed, and the agency officials recognized the need to protect this
information. We did, however, note isolated instances of forms

that were not accurate or current, and other forms that did not contain
the proper privacy notices.

Recommendations In order to meet the requirements of the Privacy Act and
other relevant laws and guidance protecting personally identifiable
information, we recommend that the Secretary of Labor ensure that the
appropriate agency officials review their data collection forms to ensure
that the electronic

forms (1) include the Paperwork Reduction Act and Privacy Act statements
and all notices, as appropriate; and (2) are valid and up to date. We also
recommend that the Secretary of Agriculture ensure that Agriculture
officials periodically determine that notices of how they share personal
information from their data collections are still valid (updating their
forms as appropriate).

Agency Comments In providing oral comments on a draft of this report,
officials at Labor, State, Agriculture, and Education* including the
Assistant Secretary for

Employment Standards at Labor, the Director of Information Management and
Liaison at State, and representatives from the offices of the Chief
Information Officers at Agriculture and Education* generally agreed with
our results. Officials also provided technical comments that we
incorporated as appropriate. In addition, Labor noted that, as we
recommended, they have now posted a valid, up- to- date electronic 3 We
have amended the briefing as of September 12, 2002, to include technical
corrections and suggestions provided by the agencies.

employee compensation form on their Web site, which includes the required
Paperwork Reduction Act and Privacy Act statements.

As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days from
the date of this letter. At that time, we will send copies to the
Secretaries of the Departments of Agriculture, Education, Labor, and
State; the Director of the Office of Management and Budget; and other
interested congressional committees. Copies will also be available at no
charge on our Web site at www. gao. gov.

Should you have any questions on matters contained in this report, please
contact me at (202) 512- 6240, or by E- mail at koontzl@ gao. gov. Other
key contributors to this report included Elizabeth Bernard, Tonia Brown,
Barbara Collier, Patricia Fletcher, Katherine Howe, Michael Jarvis,
Colleen Phillips, David Plocher, and Warren Smith.

Sincerely yours, Linda D. Koontz Director, Information Management Issues

Appendi xes Selected Agencies* Handling of Personal

Appendi x I

Information Selected Agencies Handling of Personal Information

Briefing for Staff Committee on Governmental Affairs United States Senate

August 15, 2002 As amended September 12, 2002

Briefing Outline

Background Summary of Objectives, Scope, and Methodology Results in Brief
How Agencies Handle Personal Information Agencies Handling of Personal
Information Is Generally Adequate

Information Collection Privacy Security Records Management

2

Briefing Outline ( cont d)

onclusions Recommendations Agency Comments and Our Evaluation

Background Personal Information

Personal information is all information associated with an individual and
includes both identifying information ( which can be used to locate or
identify an individual) and nonidentifying information.

Identifying information includes name, aliases, Social Security number, E-
mail address, driver s license identification number, and agency- assigned
case number.

Nonidentifying personal information includes age, education, finances,
physical attributes, and gender.

In order to obtain government services or fulfill government obligations
such as obtaining Medicare payments, applying for small business loans,
and paying taxes individuals often must provide government agencies
detailed personal information about themselves, their spouses, dependents,
and parents.

4

Background Personal Information

Widespread use of computerized recordkeeping and growth in the use of the
Internet to collect and share information have resulted in public concern
about the privacy of personal information collected by the government.
These concerns include those related to the government s ability to ensure
the accuracy and confidentiality of information about individuals and
prevent misuse of personal information. For example:

A 2001 survey from the Information Technology Association of America noted
that a majority of Americans believe that business does a better job of
protecting their information than does their government, and that
Americans are concerned ( 81% ) that their government- held personal data
may be misused.

In a September 2000 study sponsored by the Council for Excellence in
Government, by more than two to one, Americans want to proceed slowly (
65% ) rather than quickly ( 30% ) in implementing e- government because of
concerns about security, privacy, and access.

In the same survey, Americans expressed serious concern about the
potential for government employees to misuse personal information ( 55% )
and the general potential for less personal privacy ( 53% ) .

5

Background Laws and Guidance for Managing Personal Information

The Paperwork Reduction Act ( PRA) recognized that information is a
valuable government resource and must be appropriately managed throughout
its life cycle, from its collection to final disposition, whether
destruction or preservation. The act also includes specific requirements
for managing the collection of information at federal agencies. Other laws
and guidance ( such as the Privacy Act of 1974, the Computer Security Act,
and the Federal Records Act) , when combined with the PRA, describe the
life cycle framework for information management.

The Privacy Act of 1974 is the primary act regulating the federal
government s use of personal information. It places limitations on
collection, disclosure, and use of personal information maintained in
systems of records by federal agencies.

A system of records is a group of records under the control of an agency
from which information is retrieved by the name of the individual or by
some identifying number, symbol, or other particular assigned to the
individual.

One exemption under the act is routine use , which permits disclosure of a
record to governmental and nongovernmental agencies and individuals for a
purpose that is compatible with the purpose for which the information was
collected.

.

6

Background Laws and Guidance for Managing Personal Information ( cont d)

The Computer Matching and Privacy Protection Act of 1988 established
safeguards regarding an agency' s use of Privacy Act records in performing
certain computerized matching programs.

According to the act, a written computer matching agreement is required
for any computerized comparison of two or more automated systems of
records for the purposes of determining the eligibility of applicants for
assistance under federal benefits programs, or of recouping payments or
delinquent debts under federal benefits programs. Agreements are also
required for any computerized comparison of federal personnel or payroll
systems.

omputer matching agreements must specify the purpose and legal authority
for conducting the match and how these matches will be performed.

7

Background Laws and Guidance for Managing Personal Information ( cont d)

The Computer Security Act of 1987 requires agencies to develop plans for
the security and privacy of sensitive information in federal computer
systems.

The Government Information Security Reform ( GISRA) provisions in the 2001
Defense Authorization Act require agencies to establish risk- based,
agencywide information security programs, which must be independently
evaluated annually.

The Federal Records Act addresses how agencies manage records, sanctions
unlawful removal and/ or destruction of records, and provides for
submission of permanent records to the Archivist.

Major guidance for the management of personal information is found in
Office of Management and Budget ( OMB) Circular A- 130, Management of

Federal Information Resources ; National Archives and Records
Administration regulations in the U. S. Code of

Federal Regulations, Title 36; and National Institute of Standards and
Technology information security guidance.

8

Objectives, Scope, and Methodology

As agreed with your office, our objectives were to determine how agencies
are handling personal information collected on

selected information collection forms; and evaluate the adequacy of
agencies handling of personal information

against federal law, regulation, and agency guidance. 9

Objectives, Scope and Methodology ( cont d)

We selected a judgmental sample of four forms with the goal of obtaining a
range of the following:

type of information collected, e. g. , demographic, financial, medical;
collection and submission media, e. g. , paper, electronic; type of
collection, e. g. , application for a loan or grant, medical benefits

and/ or workplace compensation, receipt of a service; scope of the system,
including computer matching agreements; size of the paperwork burden; and
the categories of individuals providing the information, e. g. , farmers,

students, federal workers, and the general public. An additional selection
criterion was that the information collected through each form was
maintained in a system of records covered by the Privacy Act.

10

Objectives, Scope and Methodology ( cont d)

We chose the following four forms to review: Agriculture: Farm Service
Agency s Request for Direct Loan Assistance.

The Farm Service Agency provides direct farm ownership, direct farm
operating, and emergency loans to qualified farmers. ........ .. .. ....
.... ..... ...... .. ...... ...... . ........ .. . ....... ... .... .....
... . ...!. . ........ .. . ......".... ..... .......". . .! ... .
........ .. . .....".... ...#

Education: Office of Federal Student Aid s Free Application for Federal
Student Aid. The Office of Federal Student Aid provides schools and
financial institutions with information about a student s financial status
and loan/ grant eligibility. $. .. . . ..... ..........!. ... . ... . .!
........ ....... ... ........ ... ..........!... ......%. .... .. .....!.
..... . ... ......&'...... ..... .. #

11

Objectives, Scope and Methodology ( cont d)

Labor: Federal Employees Compensation Program s Claim for Compensation.
The Federal Employees Compensation Program provides workers compensation
coverage to federal and postal workers for employment- related injuries
and occupational diseases. Benefits include wage replacement, payment for
medical care, and ( where necessary) medical and vocational rehabilitation
assistance in returning to work. For fiscal year 2000, this program
provided 273,000 workers slightly more than $ 2 billion in benefits for
work- related injuries and illnesses.

State: Bureau of Consular Affairs Application for U. S. Passport. The
Bureau of Consular Affairs provides passports for U. S. citizens to travel
abroad. In FY 2001, a total of 7. 1 million passports were issued.

To determine how agencies are handling personal information, we conducted
structured interviews with agency officials and analyzed agency policies
and procedures. We used workflow modeling software during sessions with
agency officials to describe the steps in the process, the data flows, and
who handles the information.

12

Objectives, Scope and Methodology ( cont d)

To evaluate the adequacy of how agencies manage personal information, we
focused on information collection, privacy, security, and records
management. We reviewed relevant laws and regulations, OMB guidance, and
agency procedures. We then compared these requirements and guidance to
agency practice.

( Details of our objectives, scope, and methodology can be found in
appendix II. )

1

Results in Brief

Handling of personal information varied among the agencies studied and had
the following overall characteristics:

Agencies collected a substantial amount of personal information of a wide
variety of types, including personal identifying information ( names and
Social Security numbers) and demographic, financial, and legal data.

This information was collected from a range of categories of individuals
farmers, federal employees, students, and citizens seeking to travel
abroad. Paperwork burden the time required to fill out each form ranged
from 1to 60 minutes.

The personal information collected was shared extensively with other
federal agencies, other government entities ( state, local, tribal, and
foreign) , and private individuals and organizations.

Agency procedures for handling personal information collected were
complex, involving numerous processes and a wide range of personnel with
access to the information.

14

Results in Brief ( cont d)

The four agencies generally handled personal information adequately in the
areas reviewed: information collection, privacy, security, and records
management.

The agencies generally complied with key requirements and guidance in
these areas.

We identified isolated instances of forms that were not accurate or
current, and other forms that did not contain the proper privacy notices.

To further strengthen agency compliance with requirements for handling
personal information, we are making recommendations to the Secretaries of
Labor and Agriculture.

15

How Agencies Handle Personal Information Data Flow Characteristics

All four forms examined varied in the types of personal information
collected, in the categories of individuals supplying the information, in
the levels of burden imposed in filling them out, in the processes and
personnel involved in their handling, and in the extent of sharing with
other entities.

Types of information. For the four forms, agencies collected a substantial
amount of personal information of varying types. The following illustrates
the types of personal information collected.

Information about Individual applicant Personal identifiers Spouse Legal
name Demographic data Children Maiden name Date of birth Financial/ legal
data

Dependents Aliases Place of birth Salary Parents Home phone number
itizenship Investments Business phone number Marital status Net worth
Social Security number Date of marriage/ divorce Credit history Driver s
license number Number in household Child support Alien registration number
Education level Bankruptcy Legal address Occupation Criminal record E-
mail address Gender Drug convictions

Physical attributes, e. g. , Litigation height, eye color 16

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Categories of individuals. Many categories of individuals farmers, federal
employees, students, and U. S. citizens seeking to travel outside the
country provide personal information to request a service, receive a
financial benefit, or become eligible for a program of the federal
government.

Paperwork burden. As required by the PRA, agencies measure the paperwork
burden associated with filling out forms. The burden for these forms
ranged from 13 to 60 minutes.

17

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

The following chart provides summary information on the four forms we
reviewed.

Agency Categories of individuals Burden in minutes a Agriculture farmers
60 minutes Education students 60 minutes Labor federal employees 13
minutes State U. S. citizens 20 minutes a The amount of time needed to
fill out a form is indicated by burden hour estimates, expressed in
minutes of time. 18

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Information Sharing. For the four forms we reviewed, the agencies shared
personal information extensively with other federal government agencies,
other governmental bodies ( state, local and tribal) , and foreign
governments. Information was also shared with private entities including
individuals and organizations.

For example, sharing was done ( 1) as a routine use and ( 2) under
computer matching agreements between agencies.

19

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Routine use with other government agencies Agency Agriculture Education
Labor State ourts x x x Defense Manpower Data Center x x Department of
Justice x x x Department of Labor x Foreign governments x a HUD x Internal
Revenue Service x x Law enforcement agencies x x x x

( federal, state, local) OMB x x OSHA x Other governmental bodies x x
State agencies x x U. S. Postal Service x x a State shares information
with foreign governments only on limited occasions. 20

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Some examples of routine uses with other government agencies include the
following:

State disclose applicants mailing addresses to the Internal Revenue
Service for the purpose of enabling the IRS to locate such taxpayers to
collect taxes and other related tax activities. State also discloses to
the IRS names, dates of birth, and Social Security numbers of passport
applicants.

Education discloses personally identifying information, financial data, or
expected family contribution data from the applicants to state agencies
that have formal agreements with the Secretary of Education for the
purposes of coordinating student financial aid.

21

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Routine use with other private entities, both individuals and
organizations Agency Agriculture Education Labor State

Attorneys x x x Business firms in specified trade areas x Collection
agencies x x Consumer reporting agencies x x Contractors providing IT
services x x Credit bureaus x Financial consultants, advisors x Financial/
lending institutions x Institutions of postsecondary education x Labor
unions x Medical insurance or health plan x Parents, spouses, or immediate
families x x Parties involved in litigation x Physicians & other health
care providers x Rehabilitation agencies x 22

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Some examples of routine use with other entities included the following:
Agriculture discloses information to lending institutions when it has

determined that the farm loan applicant is financially capable of
qualifying for credit with or without a guarantee.

Education may disclose personal information, including financial data, to
institutions of postsecondary education to which the applicants have noted
that they intend to apply for admission.

Labor shares information with physicians and other health care providers
for the purpose of evaluating and/ or treating the claimant for
compensation.

2

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Education s Office of Federal Student Aid shared information under
computer matching agreements. This office had 11 such agreements with 10
agencies:

Department of Defense Department of Health and Human Services Department
of Housing and Urban Development Department of Justice Department of
Veterans Affairs Immigration and Naturalization Service Internal Revenue
Service United States Postal Service Selective Service System Social
Security Administration ( two agreements)

24

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Some of Education s computer matching agreements include matches with
Department of Justice to determine if the applicant has been convicted of
any

drug- related offense, Department of Veterans Affairs to verify an
applicant' s veteran status, Immigration and Naturalization Service to
verify the applicant s entitlement to

federal benefits, Selective Service System to verify if a male applicant
has properly registered

for the draft, and Social Security Administration to verify an applicant s
Social Security number.

25

How Agencies Handle Personal Information Data Flow Characteristics ( cont
d)

Labor shared information under computer matching agreements with the
Office of Personnel Management ( OPM) and the Social Security
Administration ( SSA) .

The agreement with OPM allows Labor to disclose employee compensation
benefit data so that OPM can compare the data to its records on retirees
and prevent payment of concurrent benefits. The agreement with SSA is a
match to ensure that dual benefits are not paid by SSA to individuals
receiving employee compensation benefits.

26

How Agencies Handle Personal Information Data Flow Modeling

Agency procedures for handling the personal information were complex.
Specifically:

The information collected was subject to numerous processes: discrete
activities performed on the data from its input to the information system
to the final outputs.

A wide range of agency personnel, with various job titles, had access to
some or all of the information on the forms. For example, at State,
personnel with job titles such as passport specialist, adjudication
manager, and consular officer had access to passport information.

27

How Agencies Handle Personal Information Data Flow Modeling ( cont d)

The following chart provides summary information on the four forms we
reviewed.

Agency Processes Job titles

Agriculture 8 8 Education 26 9 Labor 38 4 State 39 1

28

How Agencies Handle Personal Information Data Flow Modeling ( cont d)

In modeling the flow of personal information for each of these forms, we
started at a high level, depicting the following four categories.

Input channels: The approved methods to deliver the information to the
agency.

Outputs: The results or products from the processing of the information in
the system.

Laws and guidance: The generally applicable controls, identified by agency
officials, which govern the collection, use, maintenance, and disposition
of the information. They include federal law, OMB guidance, and formal
agency policies and procedures.

Agency personnel: The agency or contract employees having direct access to
some or all of the information contained on the form. They are represented
by job title, not by actual number of personnel.

We then modeled the detailed step- by- step processes for the flow of the
information on the forms, from the time it was received by the agency
through its disposition.

29

How Agencies Handle Personal Information Department of Agriculture

Agriculture s Direct Loan Application overview

Input channels Request for direct farm

Outputs

In person

loan assistance

Approved loan application Fax

Rejected loan application Mail

Withdrawn application E- mail

Personnel

8 job titles

Laws & guidance: Computer Security Act; Consolidated Farm and Rural
Development Act; Farm Service Agency Handbook and internal directives;
Federal Records Act; Freedom of Information Act; OMB Circular A- 129,
Policies for Federal Credit Programs and Non- tax Receivables; other OMB
guidance; Paperwork Reduction Act; Privacy Act; U. S. Code of Federal
Regulations, Titles 7 and 36.

30

How Agencies Handle Personal Information Department of Agriculture

Agriculture s Direct Loan Application details Farmer Submits loan

Withdraws loan application. application.

Receive application. Determine Make loan

eligibility. decision.

Four job titles: Six job titles:

Six job titles:

1 2 3 4 3 4 5 6 7

3 4 5 6 7 8

8 Loan approval notice sent to applicant.

Five subprocesses Loan rejection notice sent to applicant. 1 Program

3

Farm loan

6

District director technician manager

2

Rural development

4

Farm loan

7

Farm loan chief officer officer

5

State executive

8

State loan director

specialist 31

How Agencies Handle Personal Information Department of Education

Education s Application for Federal Student Aid overview

Input channels Student aid

Outputs

Internet

application

Student aid report to applicant Mail

Student aid eligibility to colleges E- mail

Applicant PIN

Personnel

9 job titles

Laws & guidance: Computer Security Act; Department Central Processing
System Security Plan; Office of Student Financial Assistance Guide to
Information Security and Privacy; Federal Records Act; Paperwork Reduction
Act; Privacy Act; Title IV Higher Education Act of 1965; U. S. Code of
Federal Regulations, Title 36.

32

How Agencies Handle Personal Information Department of Education

Education s Application for Federal Student Aid details

Student files aid application.

Receive application Process application,

Issue PIN to for student aid. determine eligibility,

applicant for use transmit data for

with on- line computer matching.

application system. Six job titles:

One job title: Three job titles:

1 2 3 4 5 7 6 7

8 6 1

Mail clerk Nine subprocesses Seven subprocesses

One subprocess PIN sent to 2

Document

applicant.

analyst

3

Scanning personnel

Send student aid

4

Data entry Archive paper eligibility report.

5

Batch control documentation.

personnel

6

Quality control

Student aid report

personnel

sent to student. 7

Production control

Two job titles:

Student aid report 8

Printing

sent to educational

personnel One job title:

7 8 institution. 9

9

Storage/ archive personnel

Four subprocesses 3

How Agencies Handle Personal Information Department of Labor

Labor s Claim for Federal Workers Compensation overview

Input channels Claim for

Outputs

In person

compensation

Notice of decision with appeal Mail

rights Fax

Notice to Treasury to issue

Personnel

compensation check 4 job titles

Laws & guidance: Federal Employees Compensation Act; Federal Employees
Compensation Act Procedure Manual; Paperwork Reduction Act; Privacy Act;
U. S. Code of Federal Regulations, Titles 20 and 36.

34

How Agencies Handle Personal Information Department of Labor

Labor s Claim for Federal Workers ompensation details

Employee files claim for compensation.

Receive, scan, and Locate claim. Examine claim. Complete automated

Transmit data via index compensation

compensation national office.

claim form. payment system

form and certify information.

Three job titles: One job title: One job title: One job title: Automated;
no

1 2 3 4 4

4

personnel required. Nine subprocesses

13 subprocesses 11 subprocesses Payment data

sent to Treasury. Notice of negative decision with appeal rights sent to
claimant.

1

Mailroom staff 3

Data entry personnel 2

Scanning staff 4

Examiner/ certifier 35

How Agencies Handle Personal Information Department of State

State s Passport Application overview

Input channels Application

Outputs

In person for passport

Passport issued Passport denied

Personnel

13 job titles

Laws & guidance: Acquisition and loss of U. S. citizenship, 8 U. S. C. ,
Title III; Issuance and use of U. S. passports, 22 U. S. C. 211a, et seq.
; Travel documentation of citizens, 8 U. S. C. ; Executive Order 11295,
Authority of the Secretary of State in granting and issuing U. S.
passports; Code of Federal Regulations, Title 22, Parts 50, 51, 53, and
Title 36; Foreign Affairs Manual, Title 7; Internal Passport Instructions;
Freedom of Information Act; Government Paperwork Elimination Act;
Government Performance and Results Act; Paperwork Reduction Act; Privacy
Act.

36

How Agencies Handle Personal Information Department of State

State s Passport Application details 37

Agencies Handling of Personal Information Is Generally Adequate

For the four forms, agencies were generally handling personal information
adequately in key areas: information collection, privacy, security, and
records management. We identified isolated instances of forms that were
not accurate or current and other forms that did not contain the proper
privacy notices.

The following slides provide our detailed findings in each of the four
areas. 38

Agencies Handling of Personal Information Is Generally Adequate Collection

Under the Paperwork Reduction Act, agencies are required to follow an
information review and clearance process for all forms in an information
collection.

The agency clearance process involves development of an information
collection proposal meeting specific requirements, and subsequent
evaluation and approval.

After approval by the agency Chief Information Officer, OMB then assesses
and can approve the form for a period of no longer than 3 years. OMB also
assigns a control number and an expiration date.

The agency must ensure that the form displays certain required information
including a valid control number and a specific notice required by the
PRA.

The agency is also required to provide public notice of the proposed
collection and to certify to OMB that the proposal meets PRA requirements.

39

Agencies Handling of Personal Information Is Generally Adequate Collection
( cont d)

In general, the agencies met the information collection requirements for
these four forms. However, there were some isolated problems.

Specifically, at Labor and State, the forms displayed on the Internet
showed expired OMB approvals.

In addition, Labor s electronic form did not display required PRA notices,
including

the reason for collecting the information, a description of how the
information would be used, and notice of the voluntary, required, or
mandatory nature of the responses.

40

Agencies Handling of Personal Information Is Generally Adequate Collection
( cont d)

Officials at State noted that they had submitted the clearance paperwork
to OMB, which was approved after our initial meetings with State. Labor
acknowledged that the form posted to the Internet was out of date and
needed to be brought up to date.

Without a valid OMB number, Labor and State have no authority to obtain an
individual s personal information. Further, by not having the required PRA
statements on its form, Labor is not giving individuals critical
information about their rights in filling out the form.

The following slides depict the results of our analysis of agency
compliance with legal requirements.

41

Agencies Handling of Personal Information Is Generally Adequate Collection
( cont d)

Requirements USDA Education Labor State

1. The information collection proposal includes need for the collection X
X X X description of the collection X X X X plan for the collection X X X
X whether it would be covered under the Privacy Act X X X X 2. The agency
collection review process ensures that the need was evaluated X X X X the
proper Federal Register notice is issued X X X X there is an inventory X X
X X there are policies and procedures to ensure each form displays X X X X
the correct notices an assessment of the burden hours was made X X X X 3.
The agency clearance of proposed information collections includes approval
of the CIO X X X X submission of proper material to OMB X X X X receipt of
approval for the collection and control number from X X X X OMB Unless
otherwise indicated, a check means that the condition has been met for
both paper and electronic forms.

42

Agencies Handling of Personal Information Is Generally Adequate Collection
( cont d)

Requirements USDA Education Labor State 4. The information collection
forms include proper valid control numbers X X No a No b PRA notice X X No
a X reasons for the collection X X No X description of how the information
will be used X X No X time to complete the form X X X X notice of
voluntary, mandatory, or required

X X No X responses notice that a person need not respond to the form if

X X X X a valid control number is missing 5. The agency provided public
notice for the proposed X X X X

information collection 6. The agency certified and documented that the

X X X X information submitted to OMB complies with the PRA requirements a
While the paper forms met these requirements, the electronic versions of
the form were not valid and current. b State met this requirement after
our evaluation was completed. 4

Agencies Handling of Personal Information Is Generally Adequate Privacy

Under the Privacy Act, an agency cannot disclose information about an
individual contained in a system of records without the prior consent of
the individual, unless the law authorizes the disclosure.

When agencies collect personal information, they are required to provide a
notice in the Federal Register that includes certain information, such as
the name and location of the system of records, categories of individuals
in the system, and routine uses of the information.

Agencies are to have agreements for computer matching programs. Policies
are also required for collection of personal information posted on

agency Web sites. The forms themselves must include notice of the Privacy
Act, the authority

for the collection, how the information collected will be used, the
applicant s rights under the Privacy Act, and the consequences to the
applicant of not providing the requested information.

44

Agencies Handling of Personal Information Is Generally Adequate Privacy (
cont d)

The four forms we reviewed generally complied with these requirements. At
Labor, however, the form posted on the Internet did not include a Privacy
Act notice or the required stipulations under the Privacy Act. One agency
official noted that these were on their paper version of the form, and
that the electronic version needed to be updated.

Without an explicit Privacy Act notice, individuals are not made aware of
their rights when providing personal information to Labor. It is left to
individuals to assume that privacy rights do or do not exist, which may
influence their decision to provide the information. Further, without
being informed of the effect, if any, of not providing the information,
individuals cannot make an informed decision about what information they
want to provide.

At Agriculture, the form includes a routine use ( with Labor) that is no
longer valid. Forms should be updated to reflect changes in routine uses.

The following slide depicts the results of our analysis of agency
compliance with privacy requirements.

45

Agencies Handling of Personal Information Is Generally Adequate Privacy (
cont d)

Requirements USDA Education Labor State

1. The personal information is included in a Privacy Act X X X X system of
records 2. Notice has been published in the Federal Register X X X X 3.
The Federal Register notice includes name and location of system of
records X X X X categories of individuals in the system X X X X routine
uses of the information X X X X policies and practices regarding storage
and access X X X X title and address of official responsible for the X X X
X collection

5. omputer matching agreements are in place NA X X NA 6. There are
policies for collection of personal X X X X information from agency Web
sites 7. Respondents are notified on the form the authority of the
collection and whether it is X X X a X voluntary or mandatory

how the information will be used X X X a X possible routine uses of the
information X b X X a X consequences of not providing the information X X
X a X a While the paper forms met these requirements, the electronic
versions of the form were not valid and current. b The form contains a
routine use that is no longer valid. 46

Agencies Handling of Personal Information Is Generally Adequate Security

Both the Computer Security Act and GISRA require federal agencies to
provide risk- based security protections for their information systems.
Agencies are required to identify their systems that contain sensitive
information, and develop, maintain, and periodically review security plans
for those systems. They are also required to establish an agencywide
information security program that must be annually reviewed and
independently evaluated. GISRA further requires that the agency Chief
Information Officer be responsible for supervising information security
practices at the agency.

47

Agencies Handling of Personal Information Is Generally Adequate Security (
cont d)

The four agencies showed evidence that these plans and programs were in
existence. We did not, however, verify and assess the actual
implementation of information security practices at these agencies.
Further,

GAO reports have consistently noted that information security is a high-
risk area for the government in general, with potentially devastating
consequences if it is not ensured. 1

In addition, an audit by the Agriculture Office of Inspector General (
OIG) in October 2001 found physical and operational security weaknesses at
some locations of the Farm Services Agency s payment and data systems.

The following slide depicts the results of our analysis of agency
compliance with security requirements.

1 U. S. General Accounting Office, ..... .... . ... .. ........(.)' ..' .
.*+ .. ... ...,#

48

Agencies Handling of Personal Information Is Generally Adequate Security (
cont d)

Requirements USDA Education Labor State

1. The agency has identified systems containing sensitive X X X X
information 2. The agency has an agencywide information security

X X X X program 3. The agency periodically reviews its security plans as

X X X X appropriate 4. The agency Chief Information Officer is responsible
for

X X X X a information security functions in the agency a At State, the
Bureau of Diplomatic Security shares information security responsibility.
49

Agencies Handling of Personal Information Is Generally Adequate Records
Management

Under the Federal Records Act and implementing regulations, agencies are
required to establish and maintain

an active, continuing program for the economic and efficient management of
the records of an agency; and

policies and procedures on the use, retention, disposal, and archiving of
records, as well as access to and protection of these records.

Overall, agencies were compliant with these selected records management
practices. The next slide shows detailed results.

Agency officials also noted the challenges associated with managing and
preserving electronic records. For example, State cited the need for
additional electronic records guidance from the National Archives and
Records Administration. Also, Labor recently began using a new document
management system for its federal workers compensation files. . The paper
applications are imaged and the electronic version becomes the permanent
record copy. In our June 2002 report, Information Management: Challenges
in Managing and Preserving Electronic Records ( GAO- 02- 586) , we discuss
these challenges and make recommendations to NARA to improve electronic
records management and preservation.

50

Agencies Handling of Personal Information Is Generally Adequate Records
Management ( cont d)

The following depicts the results of our analysis of agency compliance
with records management requirements.

Requirements USDA Education Labor State

1. The agency has a records management program X X X X 2. The agency has
policies and procedures to govern the X X X X

maintenance and use of records that include the approval of disposal
schedules by NARA 3. The agency has a policy for archiving information X X
X X 51

Conclusions

The collection and flow of personal information which consists of many
highly complex processes and includes substantial sharing of data with
other entities varies greatly among agencies.

For the four forms we reviewed, the agencies had policies and procedures
in place concerning information collection, privacy, security, and records
management. The agencies also generally followed key requirements of the
Privacy Act, the Paperwork Reduction Act, and other major laws,
regulations, and guidance.

However, at selected agencies there were some identified problems, such as
keeping forms and control numbers current, providing adequate Paperwork
Reduction Act and Privacy Act statements

and notifications on forms, and ensuring that routine use notice
statements are up to date.

52

Recommendations

To meet the requirements of the Privacy Act and other relevant laws and
guidance on managing personal information, we recommend that the Secretary
of Labor ensure that the appropriate agency officials review their data
collection forms so that they

are valid and up to date, and include the Paperwork Reduction Act and
Privacy Act statements and all

notices, as appropriate. We also recommend that the Secretary of
Agriculture ensure that Agriculture officials periodically assess that
their routine uses for their data collections are still valid ( updating
the forms as appropriate) .

5

Agency Comments and Our Evaluation

When commenting on a draft of this briefing, agency officials generally
agreed with the facts as presented. Also, Agriculture, Education, and
State officials provided technical corrections and suggestions, which were
incorporated as appropriate.

54

Appendi x II

Objectives, Scope, and Methodology Our objectives were to

 determine how agencies are handling personal information collected on
selected information collection forms; and

 evaluate the adequacy of agencies* handling of personal information
against federal law, regulation, and agency guidance.

We chose one form per information collection from a system of records in
each of four agencies: Department of Agriculture, Department of Education,
Department of Labor, and Department of State. We chose these

four agencies to reflect a broad range in the level of the paperwork
burden that their information collection imposed on the public; the total
paperwork burden ranged from a low of about 16.56 million hours to a high
of about 186. 11 million hours annually.

From these agencies, we selected four information collections that offered
a range of the following variables:

 the type of information collected, e. g., demographic, financial,
medical, or criminal activity;

 the collection and submission media, e. g., paper, facsimile, and/ or
electronic transactions;

 the type of collection, e. g., application for a direct or guaranteed
loan, grant or subsidy, medical benefits and/ or workplace compensation,
or receipt of a service;  the scope of the system, including computer
matching agreements;  the size of the collection burden in hours; and

 the population groups or audience using the collection, e. g., farmers,
students, federal workers, and the general public. Table 1 shows the forms
that we analyzed and their owners.

Table 1: Forms Analyzed Department Component Form OMB No.

Agriculture Farm Service Agency *Request for Direct Loan Assistance,*
0560- 0167 form FSA- 410- 1 Education Office of Federal Student Aid *Free
Application for Federal Student Aid,*

1845- 0001 form FAFSA Labor Office of Workers* Compensation *Claim for
Compensation,*

1215- 0103 Programs, Division of Federal form CA- 7 Employees*
Compensation

State Bureau of Consular Affairs *Application for U. S. Passport or
Registration,* 1405- 0004 form DS- 11 Source: Agency data.

To document the flow and practices associated with the handling of
personal information, we developed detailed data flows of each of these
forms 4 in cooperation with agency personnel involved in the direct use of
the data. First, we conducted structured interviews with top agency
officials, including Chief Information Officers and staff, to understand
the policy framework in place at the agency level. Second, we analyzed
agency documentation on policies and procedures for using, protecting, and
making available this information and mapped the procedures to the data
flows. Third, we interviewed program managers responsible for the

collection and use of the data collected on the forms to better understand
the chosen information collection. Fourth, using data modeling software,
we held in- depth data flow modeling meetings with agency staff who
received, processed, maintained, and disposed of the data, as well as with
the program managers responsible for the systems. Fifth, we submitted the
model of the flow of personal information to the system users for their
feedback to ensure the model*s validity. Finally, we reviewed past GAO
reports for relevant information on information collection, privacy,
security, and records management.

In order to evaluate the information flows and practices against agency
and federal guidance, we reviewed applicable laws and regulations and met
with and obtained documentation from appropriate agency officials. We
identified the key requirements of the laws and then compared these with

4 We used a data flow modeling tool called Workflow Analyzer from Meta
Software to map the flow of personal information on each form.

agency practices. Our review of laws covered the Privacy Act of 1974, the
Computer Matching and Privacy Protection Act of 1988, the Paperwork
Reduction Act of 1995, the Government Paperwork Elimination Act of 1998,
the Computer Security Act of 1987, the Government Information

Security Reform Act of 2000, the Federal Records Act, and the Code of
Federal Regulations. We also reviewed pertinent OMB guidance. We conducted
our review from March 2001 to July 2002, in accordance with generally
accepted government auditing standards.

Selected Bibliography General Internal Revenue Service Technical Manual,
Office of Privacy Advocate. Privacy Impact Assessment. Version 1.3.
Washington, D. C.: December 17,

1996. Office of Management and Budget. FY 2001 Report to Congress on
Federal Government Information Security Reform. Washington, D. C.:
February 13, 2002.

Office of Management and Budget, OIRA. Managing Information Collection and
Dissemination: Fiscal Year 2002. Washington, D. C.: n. d.

Privacy Working Group, Information Policy Committee, Information
Infrastructure Task Force. Privacy and the National Information
Infrastructure: Principles for Providing and Using Personal Information.
Washington, D. C.: June 6, 1995.

SRA International, Inc. Report on Current Recordkeeping Practices within
the Federal Government. Prepared for the National Archives and Records
Administration. Arlington, VA: December 10, 2001.

Agriculture Department of Agriculture, Office of Inspector General, Great
Plains Region. Farm Service Agency/ Commodity Credit Corporation: Security
Over Information Technology Resources. 03099- 47- KC. Washington, D. C.:
October 31, 2001.

Education Department of Education, Office of Inspector General, Final
Audit Report on Audit of the Department*s Records Management Program.
EDOIG/ A11- A0011. Washington, D. C.: September 2001.

Related GAO Products General Paperwork Reduction Act: Changes Needed to
Annual Report. GAO- 02-

651R. Washington, D. C.: April 29, 2002.

Social Security Numbers: SSNs Are Widely Used by Government and Could Be
Better Protected. GAO- 02- 691T. Washington, D. C.: April 29, 2002.

Paperwork Reduction Act: Burden Increases and Violations Persist. GAO02-
598T. Washington, D. C.: April 11, 2002.

Information Resources Management: Comprehensive Strategic Plan Needed to
Address Mounting Challenges. GAO- 02- 292. Washington, D. C.: February 22,
2002.

U. S. Postal Service: Update on E- Commerce Activities and Privacy
Protections. GAO- 02- 79. Washington, D. C.: December 21, 2001.

Computer Security: Improvements Needed to Reduce Risk to Critical Federal
Operations and Assets. GAO- 02- 231T. Washington, D. C.: November 9, 2001.

Electronic Government: Challenges Must Be Addressed With Effective
Leadership and Management. GAO- 01- 959T. Washington, D. C.: July 11,
2001.

Record Linkage and Privacy: Issues in Creating New Federal Research and
Statistical Information. GAO- 01- 126SP. Washington, D. C.: April 1, 2001.

Information Management: Progress in Implementing the 1996 Electronic
Freedom of Information Act Amendments. GAO- 01- 378. Washington, D. C.:
March 16, 2001.

Information Security: Advances and Remaining Challenges to Adoption of
Public Key Infrastructure Technology. GAO- 01- 277. Washington, D. C.:
February 26, 2001.

High- Risk Series: An Update. GAO- 01- 263. Washington, D. C.: January 1,
2001.

Electronic Government: Government Paperwork Elimination Act Presents
Challenges for Agencies. GAO/ AIMD- 00- 282. Washington, D. C.: September
15, 2000.

Internet Privacy: Comparison of Federal Agency Practices with FTC*s Fair
Information Principles. GAO/ AIMD- 00- 296R. Washington, D. C.: September
11, 2000.

Internet Privacy: Agencies* Efforts to Implement OMB*s Privacy Policy.

GAO/ GGD- 00- 191. Washington, D. C.: September 5, 2000.

Electronic Government: Federal Initiatives Are Evolving Rapidly But They
Face Significant Challenges. GAO/ T- AIMD/ GGD- 00- 179. Washington, D.
C.: May 22, 2000.

Information Technology: Comments on Proposed OMB Guidance for Implementing
the Government Paperwork Elimination Act. GAO/ AIMD99- 228R. Washington,
D. C.: July 2, 1999.

Corps of Engineers Electronic Signature System. GAO/ AIMD- 97- 18R.
Washington, D. C.: November 19, 1996.

Agriculture Farm Loan Programs: Improvements in the Loan Portfolio but
Continued Monitoring Needed. GAO- 01- 732T. Washington, D. C.: May 16,
2001.

USDA Electronic Filing: Progress Made, But Central Leadership and
Comprehensive Implementation Plan Needed. GAO- 01- 324. Washington, D. C.:
February 28, 2001.

Information Security: USDA Needs to Implement Its Departmentwide
Information Security Plan. GAO/ AIMD- 00- 217. Washington, D. C.: August
10, 2000.

Information Security: Software Change Controls at the Department of
Agriculture. GAO/ AIMD- 00- 186R. Washington, D. C.: June 30, 2000.

USDA Information Security: Weaknesses at National Finance Center Increase
Risk of Fraud, Misuse, and Improper Disclosure. GAO/ AIMD- 99- 227.
Washington, D. C.: July 30, 1999.

Education Student Financial Aid: Use of Middleware for Systems Integration
Holds Promise. GAO- 02- 7. Washington, D. C.: November 30, 2001.

Education Information Security: Improvements Made But Control Weaknesses
Remain. GAO- 01- 1067. Washington, D. C.: September 12, 2001.

Financial Management: Internal Control Weaknesses Leave Department of
Education Vulnerable to Improper Payments. GAO- 01- 585T. Washington, D.
C.: April 3, 2001.

Major Management Challenges and Program Risks: Department of Education.
GAO- 01- 245. Washington, D. C.: January 1, 2001.

Student Loans: Improvements in the Direct Loan Consolidation Process. GAO/
HEHS- 99- 19R. Washington, D. C.: November 10, 1998. Labor Office of
Workers* Compensation Programs: Further Actions Are Needed

to Improve Claims Review. GAO- 02- 637. Washington, D. C.: May 9, 2002.

Office of Workers* Compensation Programs: Further Actions Are Needed to
Improve Claims Review. GAO- 02- 725T. Washington, D. C.: May 9, 2002.

Department of Labor: Status of Achieving Key Outcomes and Addressing Major
Management Challenges. GAO- 01- 779. Washington, D. C.: June 15, 2001.

Workers* Compensation: Action Needed to Reduce Payment Errors in SSA
Disability and Other Programs. GAO- 01- 367. Washington, D. C.: May 4,
2001.

Office of Workers* Compensation Programs: Goals and Monitoring Are Needed
to Further Improve Customer Communications. GAO- 01- 72T. Washington, D.
C.: October 3, 2000.

Information Security: Software Change Controls at the Department of Labor.
GAO/ AIMD- 00- 192R. Washington, D. C.: June 30, 2000.

Major Management Challenges and Program Risks: Department of Labor.

GAO/ OCG- 99- 11 Washington, D. C.: January 1, 1999.

Federal Employees* Compensation Act: Percentages of Take- Home Pay
Replaced by Compensation Benefits. GAO/ GGD- 98- 174. Washington, D. C.:
August 17, 1998. State Electronic Signature: Sanction of the Department of
State*s System. GAO/ AIMD- 00- 227R. Washington, D. C.: July 10, 2000.

Information Security: Software Change Controls at the Department of State.
GAO/ AIMD- 00- 199R. Washington, D. C.: June 30, 2000.

(310350)

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a

GAO United States General Accounting Office

Why GAO Did This Study

To obtain government services, members of the public must often provide
agencies with personal information, which includes both identifying
information (such as a name or Social Security number, which can be used
to locate or identify someone) and nonidentifying information (such as age
or gender). GAO was asked to review agencies* handling of the personal
information they collect and whether this handling conforms with federal
law, regulation, and agency guidance.

September 2002 INFORMATION MANAGEMENT Selected Agencies* Handling of
Personal Information

This is a test for developing highlights for a GAO report. The full
report, including GAO*s objectives, scope, methodology, and analysis is
available at www. gao. gov/ cgi- bin/ getrpt? GAO- 02- 1058. For
additional information about the report, contact Linda Koontz (202- 512-
6240). To provide comments on this test highlights, contact Keith Fultz
(202- 512- 3200) or E- mail HighlightsTest@ gao. gov.

Highlights of GAO- 02- 1058, a report to the Chairman, Committee on
Governmental Affairs, U. S. Senate

What GAO Recommends

To strengthen agency compliance with requirements for handling personal
information, GAO recommends that the Secretary of Labor ensure that data
collection forms are up to date and include appropriate Privacy Act and
other notices. GAO also recommends that the Secretary of Agriculture
ensure that the notices of how the department shares forms data be
assessed and forms updated as appropriate.

Labor, Agriculture, Education, and State officials generally agreed with
GAO*s report. In addition, Labor officials posted a valid, up- to- date
form as recommended.

United States General Accounting Office

What GAO Found

GAO reviewed the processes used in handling personal information collected
from the public on forms at four different agencies* Agriculture,
Education, Labor, and State. These four agencies were chosen because their
forms represent a range of characteristics, including the time needed to
fill them out (the total paperwork burden hours) and the purpose of the
information they collect. In reviewing these forms, GAO concentrated on
four areas (information collection, privacy, security, and records
management).

Handling of personal information varied among the agencies studied.
Overall, agencies collected a substantial amount of personal information
of a wide variety of types, including personal identifying information
(names and Social Security numbers) and demographic, financial, and legal
data (see display below). Agency procedures for handling personal
information collected were complex, involving numerous processes and a
wide range of personnel with access to the information. The personal
information collected was shared extensively with other federal agencies,
other government entities (state, local, tribal, and foreign), and private
individuals and organizations through authorized procedures.

The agencies generally complied with the key requirements and guidance
pertaining to information collection, privacy, security, and records
management. However, GAO identified isolated instances of forms that were
not accurate or current; other forms did not contain the proper privacy
notices.

Agencies Collect Many Types of Personal Information Information about

Individual applicant Personal identifiers

Spouse Legal name Demographic data

Children Maiden name Date of birth Financial/ legal data

Dependents Aliases Place of birth Salary Parents Home phone number
Citizenship Investments

Business phone number Marital status Net worth Social Security number Date
of marriage/ divorce Credit history Driver*s license number Number in
household Child support Alien registration number Education level
Bankruptcy Legal address Occupation Criminal record E- mail address Gender
Drug convictions

Physical attributes, e. g., Litigation height, eye color

Source: GAO analysis. G A O Accountability Integrity Reliability

Highlights

Page i GAO- 02- 1058 Information Management

Contents Letter 1

Recommendations 2 Agency Comments 2

Appendixes

Appendix I: Selected Agencies* Handling of Personal Information 4

Appendix II: Objectives, Scope, and Methodology 58 Selected Bibliography
61 Related GAO Products 62 Table Table 1: Forms Analyzed 59

Page 1 GAO- 02- 1058 Information Management United States General
Accounting Office

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Appendix I Selected Agencies* Handling of Personal Information

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Appendix I Selected Agencies* Handling of Personal Information

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Appendix I Selected Agencies* Handling of Personal Information

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Appendix II

Appendix II Objectives, Scope, and Methodology

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Appendix II Objectives, Scope, and Methodology

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United States General Accounting Office Washington, D. C. 20548- 0001

Official Business Penalty for Private Use $300

Address Service Requested Presorted Standard

Postage & Fees Paid GAO Permit No. GI00
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